Contract analysis

Section 1: Documents Produced 1.1 Glenmore Bank Ireland plc Account Statements PBI's principal Irish banking institution is Glenmore Bank Ireland plc ("Glenmore Bank"), a public limited company organized and existing under the laws of Ireland, regulated by the Central Ridgeway Trust Bank, and headquartered in Dublin. Glenmore Bank has served as PBI's primary banking institution since PBI's incorporation in March 2012

Section 2: Relevance of Produced Documents to PBI's Economic Substance PPC respectfully submits that the banking records and related documentation produced in response to IDR No. 22 are directly relevant to, and provide substantial support for, PBI's independent economic substance in Ireland — a key factual issue in the current examination. The Glenmore Bank account statements, account opening documentation, and Trea

Section 3: Coordination with Irish Tax Advisors PPC notes that certain of the documents produced in response to IDR No. 22 were obtained in coordination with Thornbury & Keogh, Chartered Tax Advisors, of 22 Fitzwilliam Square, Dublin 2, D02 YH68, Ireland. Thornbury & Keogh serves as PBI's Irish tax advisors, and the coordination with that firm was led by partner Ciarán Thornbury. Mr. Thornbury's team assisted in the

Section 4: Privilege Reservation and Document Index 4.1 Privilege Reservation PPC expressly reserves all rights to assert the attorney-client privilege and the work-product protection doctrine over any documents, communications, or other materials that have not been produced in connection with IDR No. 22 or any other Information Document Request issued during this examination. The production of banking records and re

Section 5: Supplementary Notes PPC offers to make PBI's finance personnel, including members of PBI's treasury team and the Head of Finance, available for interview or follow-up questions regarding the banking records and treasury operations documented in the enclosed production. PPC recognizes that the volume and complexity of the produced materials may give rise to questions, and PPC is committed to facilitating th